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Industry groups are pressing the Cybersecurity and Infrastructure Security Agency (CISA) to narrow and clarify its proposed rule for reporting cyber incidents at critical infrastructure organizations. Their main concerns are who would be covered, what counts as a reportable incident, how much information must be supplied during a response, and whether the new process would duplicate existing federal reporting.
The underlying law, the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA), sets statutory deadlines: covered entities must report a covered cyber incident within 72 hours and a ransomware payment within 24 hours. CISA’s proposed rule is intended to define which entities and incidents fall within those obligations and how reporting would work. The detailed definitions remain proposed requirements, not settled law.
Why trade groups are still objecting
The objections have appeared in successive rounds of industry input. In October 2024, 21 infrastructure-related organizations representing fields including communications, energy, aviation, information technology and transportation asked then-CISA Director Jen Easterly for more extensive engagement and narrower key definitions. The coalition warned that, without greater engagement, the proposal could impose requirements that hinder rather than help security and operational efficiency.
By June 2026, speakers at CISA town halls were raising similar questions in more practical terms: how wide the covered population would be, what activity would trigger a report, and whether organizations could gather extensive information while containing an incident. Federal News Network reported that more than 1,200 stakeholders attended the town-hall series. CyberScoop reported CISA estimated that more than 300,000 entities could be covered under its approach.
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These are connected but distinct concerns. A broad coverage test could bring many organizations into scope; an unclear incident threshold could make routine activity seem reportable; and an extensive data request could compete with the immediate work of investigation and recovery.
Who should count as a covered entity?
Trade groups argue that broad sector or organizational-size criteria may not identify the organizations whose disruption would pose the greatest systemic risk. In its June 15, 2026 submission, Business Roundtable said revenue and employee thresholds are unreliable proxies: broad criteria could sweep in entities whose disruption would not have a debilitating effect while missing smaller operators that are systemically important.
Business Roundtable recommended tying coverage to demonstrable systemic risk and critical functions, and clarifying that incidental involvement in a critical infrastructure sector should not, by itself, make an organization covered. That is an advocacy position, not a rule CISA has adopted. The competing policy challenge is to create a perimeter broad enough to reveal risks across interconnected sectors without treating every business with a sector connection as equally critical.
What activity should trigger a report?
Stakeholders want a clear line between consequential cyber incidents and routine or inconsequential activity. At a June town hall, Grant MacIntyre, director of regulatory affairs and senior attorney at the Auto Care Association, put the scope concern bluntly: “The rule includes too many companies.”
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Tim Pospisil, chief security officer for Nebraska Public Power District, described his worry that organizations could be asked to report whenever a foreign entity “tickles our firewall,” even if it only pings or searches. That is his characterization of the concern, not the proposed rule’s legal definition of a reportable incident.
Business Roundtable recommended anchoring “substantial cyber incidents” to consequential impacts and excluding non-exploited vulnerabilities, good-faith security research and routine low-level activity. The practical distinction matters: a rule that is unclear about the threshold may encourage over-reporting to avoid missing a deadline, while an overly narrow test could leave government with less visibility into serious threats.
How much information can organizations provide on a short clock?
CIRCIA’s statutory deadlines leave a short window for an initial report: 72 hours for a covered cyber incident and 24 hours for a ransomware payment. Industry groups question whether organizations can accurately assemble extensive details while also containing an active incident. Business Roundtable urged CISA to reduce data elements that may be difficult to determine within the 72-hour period.
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Would CIRCIA duplicate other reporting requirements?
Organizations may already face incident-reporting obligations to other federal agencies or sector regulators. A 2026 Congressional Research Service report describes differences in definitions, deadlines and reporting destinations across CIRCIA and other Department of Homeland Security requirements. Those inconsistencies can create uncertainty about what to report, where and when.
Harmonizing requirements could reduce duplicate work, but a single process may not fit every sector’s risk or operational needs. The policy choice is not simply centralized reporting versus no reporting: it is how to give the government a useful cross-sector picture while preserving sector-specific requirements where they serve distinct purposes.
In December 2024, former Assistant National Cyber Director for Cyber Policy and Programs Nick Leiserson described the issue as “a coordination problem inside the government,” arguing that the trade-off was within government. CISA’s rationale for a central reporting channel is that it can provide visibility across sectors, help direct assistance to victims, reveal patterns and support warnings to potential victims. The debate is over whether the resulting system can deliver those benefits without imposing confusing or redundant obligations.
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Reports in June and July 2026 described CISA’s rule as pending. A July report said the Unified Agenda showed September 2026 as a target for the final rule, but that date was not a guarantee: in June, CISA’s acting director told reporters he had no particular date to give. The schedule and the final requirements therefore remained unsettled in the cited reporting.
Until CISA publishes a final rule, organizations should distinguish the statute’s reporting deadlines from the proposal’s still-pending definitions of covered entities, reportable incidents and required information. The 2026 objections show that trade groups are asking the agency to resolve those implementation questions with clearer thresholds, more focused coverage and a manageable reporting process.
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